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EC decision

Front & Simcoe, Limited v. Minister of National Revenue, [1960] CTC 123, 60 DTC 1081

In that connection, reference may be made to the speech of Lord Tomlin in C.I.R. v. ...
EC decision

Espie Printing Company Limited v. Minister of National Revenue, [1960] CTC 145, 60 DTC 1087

There was no illegality suggested in connection with the commissions and other items mentioned in Schedule B, and in my opinion they are deductible as well. ...
EC decision

Sterling Paper Mills Inc. v. Minister of National Revenue, [1960] CTC 215, 60 DTC 1171

In that matter the company had acquired a number of timber limits and had disposed of them in three different sales, because, although they had been acquired for the purpose of being used in the operation of its saw mill, it found that they were unusable in connection therewith. ...
EC decision

Harvey Clarke Smith v. Minister of National Revenue, [1960] CTC 391, 60 DTC 1282

According’ to the appellant, the reason for taking the title in his father’s name was that, ‘He was a business man and I was not and he looked after all the details in connection with the business.’’ ...
EC decision

Federal Farms Limited v. Minister of National Revenue, [1959] CTC 98, 59 DTC 1050

It is also established that for income tax purposes all of the expenses incurred in the seeding and cultivation of the crops destroyed were allowed as deductible operating expenses, aS well as all the expenses occasioned by the flooding and in connection with which the amount in question was spent. ...
EC decision

Lee Sheddy v. Minister of National Revenue, [1959] CTC 132, 59 DTC 1073

The first meeting of the Drumheller Leaseholds was held on December 19, 1950, and the minutes show that the members authorized the officers and directors ‘‘to consider any deals and carry out correspondence with all interested parties in connection with our holdings’’. ...
EC decision

Minister of National Revenue v. The People’s Thrift and Investment Co., [1959] CTC 185, 59 DTC 1129

., pursuant to a legal obligation to pay interest on (i) borrowed money used for the purpose of earning income from a business or property (other than property the income from which would be exempt), or (ii) an amount payable for property acquired for the purpose of gaining or producing income therefrom or for the purpose of gaining or producing income from a business (other than property the income from which would be exempt),... 12. (1) In computing income, no deduction shall be made in respect of (c) an outlay or expense to the extent that it may reasonably be regarded as having been made or incurred. for the purpose of gaining or producing exempt income or in connection with property the income from which would be exempt,” The appellant bases his appeal on the ground that the interest amounting to $20,704.15 was in respect of the purchase of prop- erty the income from which would be exempt within the meaning of the above sections and that the said amount was not interest on borrowed money used for the purpose of earning income from the respondent’s business within the meaning of Section 11(1) (c) of the Act. ...
EC decision

J.-Euclide Perron, Limitee v. Minister of National Revenue, [1962] CTC 457

Joignons que les articles 21, 22 et 30 des procédures d’appel allèguent subsidiairement, mais sans établir de connexion légale entre les parties, l’explication suivante: “21. ...
EC decision

The Queen v. Continental Air Photo Ltd., [1962] CTC 495, [1962] DTC 1306

He, however, admits that sometimes the word ‘‘portrait’’ can be used in connection with a pet, such as a dog or a horse, if there was a great deal of skill used in the lighting of the head. ...
EC decision

George H. Steer v. Minister of National Revenue, [1965] CTC 181, 65 DTC 5115

The appellant i is a well-known and highly respected practising lawyer in the Province of Alberta who, quite apart from his practice of law, has, on at least one occasion, embarked on a business venture in connection with oil and gas properties resulting in profits upon which he has paid income tax. ...

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